WHY NOT GIVE MARYLAND "FULL FAITH & CREDIT?"

In Rockland Industries, Inc. v. Horowitz, Rockland Industries wanted to enforce a "foreign" judgment it had obtained in the State of Maryland against Robert Horowitz, and others, upon the defendants' failure to answer or appear in a Maryland lawsuit.

After Horowitz was unsuccessful getting Maryland's courts to annul the judgment (on jurisdictional grounds), Rockland sought to enforce the judgment here in New York.

Horowitz again argued that since Maryland hadn't obtained personal jurisdiction over him, its judgment couldn't be honored. When the Queens County Supreme Court sided with Horowitz and denied Rockland's enforcement efforts, the company appealed to the Appellate Division, Second Department, which reversed and granted relief in Rockland's favor.

Since Maryland had already decided the jurisdictional question, it couldn't be revisited by a New York court. As a result, the AD2 was of the opinion the lower court had erred by refusing to give "full faith and credit" to the Maryland judgment.

Rockland's money judgment was solid ....

To download a copy of the Appellate Division's decision, please use this link: Rockland Industries, Inc. v. Horowitz